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The Avocado Surveillance Sampling Program

What it is, and what it’s not
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Last May, the U.S. Food and Drug Administration (FDA) began a new program to sample imported and domestically-grown whole pit avocados to test for microbiological contamination. Aptly named the “Avocado Surveillance Sampling Program Pilot,” testing is already underway and is expected to conclude by May 2015.

Why Has the FDA Created This ‘Surveillance’ Program?
The FDA has long collected information about the contamination of imported and domestic produce and other foods to develop new food safety policies and procedures. In conducting this type of surveillance sampling program, FDA is typically interested in determining the rate of contamination and in developing regulatory procedures to protect consumers and foster corrective action by the food industry.

The Food Safety Modernization Act (FSMA) was cited by FDA as a part of the reason for the microbiological contamination sampling program pilot. Although section 205 of FSMA (titled “Surveillance”) does not provide additional authority to the FDA to conduct surveillance sampling activities, it does require the agency to review its strategies to coordinate and share information with the Centers for Disease Control and Prevention (CDC).

Further, although the FDA is required to identify high risk foods, it is uncertain to what extent “high risk” foods—for purposes of surveillance sampling—may correspond to any future import certification requirements under FSMA sections 303 or 204.

The microbiological contamination surveillance sampling program pilot has three elements. The first is the goal of collecting statistically significant contamination data so the FDA may proactively identify public health risks. In announcing this new sampling program for avocados, FDA is acknowledging previous sampling approaches had not yielded the hoped for results. This was partly because past surveillance practices were deemed as overly broad and did not yield statistically significant results.

The second element focuses on foods that present the greatest public health risk. Criteria for identifying these high risk foods include their contribution to foodborne illness outbreaks, level of consumption (generally or by high- risk populations), ready-to-eat foods or ingredients thereof, foods that regularly come into contact with known contaminated sources, and foods that are cooked by consumers or processed without a ‘kill’ step (i.e., actions to destroy pathogenic microorganisms).

On the basis of these criteria, in part, FDA identified a number of food products to be used in various surveillance sampling pilot programs, including imported and domestically-produced whole pit avocados.

While the domestic avocado industry has stressed that fresh avocados are a low-risk product, CDC reports have suggested that while avocados alone have not been directly implicated in foodborne illness outbreaks, guacamole has arisen as a vehicle of foodborne illness outbreaks, and of course, avocados are the principal ingredient of guacamole. The FDA’s notice also indicated that avocados do have characteristics associated with susceptibility to some microbiological pathogens.